Public consultation on the NHMRC s draft revised Australian alcohol guidelines for low-risk drinking

Transcription

1 Public cnsultatin n the NHMRC s draft revised Australian alchl guidelines fr lw-risk drinking Recmmendatins frm The Cancer Cuncil Australia The Cancer Cuncil Australia is Australia s peak nn-gvernment cancer cntrl rganisatin, representing the natinal bjectives f the eight state and territry Cancer Cuncils. The Cancer Cuncil s netwrk f evidence-based, expert advisry grups includes its Natinal Nutritin and Physical Activity Cmmittee, cmprising scientists and ther public health prfessinals frm a range f disciplines relating t cancer cntrl and nutritin and physical activity. Respnsibility fr cntent in this submissin is taken by Prfessr Ian Olver, Chief Executive Officer, The Cancer Cuncil Australia. Crrespndence t Paul Grgan, Directr, Advcacy, The Cancer Cuncil Australia, c/ paul.grgan@cancer.rg.au r (02)

2 Key pints and recmmendatins in summary The NHMRC is cmmended fr this revised draft, which recmmends a safer daily alchl cnsumptin limit fr men and includes an increased fcus n cancer, cnsistent with emerging evidence. The guidelines shuld recmmend a limit f ne standard drink per day fr wmen, cnsistent with the NHMRC s dietary guidelines and with evidence n cancer risk assciated with bth alchl as a carcingen and with weight gain as a cnsequence f alchl cnsumptin. The guidelines shuld identify alchl as a carcingen, cnsistent with the findings f the Internatinal Agency fr Research n Cancer, and incrprate imprtant new evidence reprted in the Wrld Cancer Research Fund s Fd, nutritin, physical activity, and the preventin f cancer: a glbal perspective (2007). T cmplement the prvisin f updated new alchl guidelines, nutritinal infrmatin n the energy cntent f alchlic beverages shuld be mandatry n all cntainers and recmmended in the guidelines. The guidelines require an increased emphasis n lng-term harms, cnsistent with the ratinale, t balance the disprprtinate fcus n behaviural/immediate harms. The Additinal health advice and precautins fr specific grups f adults wh have an increased risk sectin shuld include separate recmmendatins fr peple with elevated risk f alchl-related cancers thrugh family histry, including advice that abstinence may be the safest ptin in such cases. Discussin thrughut the draft guidelines f the ptential benefits f lw-level alchl cnsumptin in prtecting against heart disease shuld include statements advising that there are a range f alternative ways t prevent heart disease which, unlike alchl cnsumptin, carry n risk f cancer. Appendix 5 shuld elabrate n and distinguish between the nutritinal and pharmaclgical prperties f alchl t add imprtant cntext t the evidence n the risk f alchl-related diseases. 2

3 Overview The Cancer Cuncil Australia cmmends the NHMRC fr revising its Australian Alchl Guidelines: health risks and benefits (2001) and fr cnsulting publicly n the develpment f updated guidelines. The Cancer Cuncil Australia welcmes the increased fcus n cancer thrughut the draft revised Australian alchl guidelines fr lw-risk drinking ( the draft ), cnsistent with the emergence f significant new evidence ver recent years shwing an increase in the link between alchl cnsumptin and cancer. This brief submissin cnsists f summary recmmendatins; an verview; ratinale; emerging evidence; and specific cmments addressing individual statements and missins thrughut the draft. The Cancer Cuncil Australia s cmments are fcused n Guideline 1, which is mst relevant t cancer risk. We strngly endrse the prpsal in the draft t reduce the recmmended number f standard drinks per day fr Australian men frm fur t tw. The Cancer Cuncil Australia als strngly recmmends that the NHMRC reduce the recmmended limit f standard alchlic drinks fr wmen frm tw t ne, in rder t reduce cancer risk. This wuld als be cnsistent with the NHMRC s advice n alchl in the Australian Dietary Guidelines. The Cancer Cuncil Australia als believes that the draft has disprprtinate emphasis n the scial and behaviural harms assciated with alchl cnsumptin; recmmending a limit f ne standard drink per day fr wmen wuld in ur view redress this imbalance. Specific areas in the text are highlighted under the heading Addressing specific statements, belw. In additin, references thrughut the draft t the ptential benefits f lw-level alchl cnsumptin in prtecting against heart disease shuld include statements advising that there are a range f ther ways t prevent heart disease which, unlike alchl cnsumptin, carry n risk f cancer. These ccur n page 16, paragraph 3; page 29, paragraph 2; page 30, paragraph 2; page 43, paragraph 5; and page 99, paragraph 1. The Additinal health advice and precautins fr specific grups f adults wh have an increased risk sectin shuld include separate recmmendatins fr peple with elevated risk f alchl-related cancers thrugh family histry, including advice that abstinence may be the safest ptin in such cases. This is particularly imprtant fr peple at genetic risk f breast and cln cancers. Mre generally, a number f the diseases discussed in appendix 5 (and all f the chrnic diseases linked t alchl cnsumptin) are diseases f nutritinal bichemistry, nt the pharmaclgical effects f alchl. It is imprtant t therefre distinguish between and elabrate n the nutritinal and pharmaclgical prperties f alchl t add necessary cntext. 3

4 Ratinale Tw fr men, ne fr wmen There are a number f imprtant reasns and supprting evidence fr recmmending a limit f tw standard drinks fr men per day and ne fr wmen, including: Tw and ne is cnsistent with the NHMRC Dietary guidelines fr Australian adults (2003), which recmmend n mre than ne drink per day fr wmen. This recmmendatin is based n the link between alchl cnsumptin and weight gain. Recmmendatins n alchl cnsumptin shuld be cnsistent in bth the dietary and lw-risk drinking guidelines, as weight gain is an imprtant health cncern and a risk factr fr cancer. Weight gain is a particularly imprtant risk factr fr cancer in wmen, with tw f the mst cmmn cancers diagnsed in Australian wmen, bwel and (pstmenpausal) breast cancer, linked t verweight/besity. The cnfusin in Australia between standard drinks and serving sizes, discussed n pages 19 and 20 f the draft, shws the imprtance f recmmending the safer and lwer cnsumptin level fr wmen, as serving sizes tend t be larger than standard drinks. Sectins 2.3 (page 24) 3.3 (page 31) f the draft largely verlk the significant differences in alchl metablism between men and wmen and the impact these have n bld alchl cncentratin and cnsequent disease risk. Sectin 3.4 (page 32) cmpares the physilgical effects f alchl cnsumptin n wmen with the behaviural effects n men in the cntext f lifetime risk. The Cancer Cuncil Australia s view is that this is an incngruus cmparisn, which may further understate the cancer risk t wmen f tw standard drinks per day. The metablic issues relating t wmen expressed in sectin 3.4 add t the requirement fr wmen t have a lwer recmmended daily cnsumptin limit than men and shuld be reprted in that cntext. Recmmendatin 6 in chapter 12 (pages ) f the latest cmprehensive Wrld Cancer Research Fund (WCRF) study n alchl and cancer states If alchlic drinks are cnsumed, limit cnsumptin t n mre than tw drinks a day fr men and ne drink a day fr wmen. 1 (See belw fr imprtant additinal infrmatin abut the WCRF study.) Additinal evidence and statements thrughut the draft supprt recmmending a daily limit f ne standard drink fr wmen, including: the risk f death frm alchl-related disease escalates much mre rapidly fr wmen than fr men (page 9) fr any given level f drinking, wmen have a higher relative risk f injury (page 41) 4

5 English et al, 1995, Hlman et al 1996 recmmend 1-2 Australian standard drinks fr men and 0-1 fr wmen (page 44) review by Burger et al, 2004 led t 10-12g/day (1-1.2 std drinks) fr wmen and 20-24g/day (2-2.4 std drinks) fr men (page 44). Emerging evidence The Cancer Cuncil Australia recgnises the extensive research and literature review invlved in the draft. We recmmend that, where apprpriate, references t the Wrld Cancer Research Fund s Fd, nutritin, physical activity, and the preventin f cancer: a glbal perspective, published in 2007, 1 be added, particularly in the intrductin. This, the secnd WCRF reprt n alchl and cancer (inter alia), is a majr additin t the evidence base n cancer risk linked t alchl cnsumptin and prvides direct cmparisns with the first reprt published in The 2007 WCRF reprt includes detailed analyses f the risks relating t specific cancer sites. Amng its mst imprtant findings is evidence that any level f alchl cnsumptin may increase cancer risk (see belw). Addressing individual statements Draft statement: Page 11, table 1, Guideline 1. Men and wmen Tw standard drinks r less in any ne day. Cancer Cuncil recmmendatin: Men: tw standard drinks r less in any ne day. Wmen: ne standard drink r less in any ne day. Draft statement: Page 15, sectin 1.1, paragraph 1. Alchl is described as a txin and teratgen, but nt as a carcingen. Cancer Cuncil recmmendatin: State in the intrductin that alchl is recgnised as a carcingen. 2 Draft statement: Page 29, bullet pint 3 (first discussin n cancer): alchl is assciated with an increased risk f cancer verall, and is a cause f cancer f the muth, thrat and esphagus. Alchl is als a risk factr fr ther cancers, such as cancer f the stmach, breast and liver, and has als been assciated with bwel cancer. Cancer Cuncil recmmendatins: The draft text may understate the alchlrelated risks f breast and bwel cancer. Fr additinal cntext, it shuld als highlight that breast and bwel cancers are the secnd and third mst cmmn cancers in Australia respectively. Prpsed statement: Cnvincing evidence shws alchl cnsumptin increases the risk f cancers f the muth, pharynx, larynx, esphagus and liver (men and wmen), bwel cancer in men and breast cancer (pre- and pst-menpause) in wmen. Evidence als shws alchl 5

6 cnsumptin is a prbable cause f clrectal cancer in wmen. 1 Alchl is als a risk factr fr ther cancers, such as cancer f the stmach and pancreas. (Bwel and breast cancer are the secnd and third mst cmmn cancers in Australia respectively. 3 ) Draft statement: Page 30, Table 3.1 (rw 2, clumn 2), cln. Culd be perceived as verlking rectal cancer. Cancer Cuncil recmmendatins: Replace cln with bwel. Draft statement: Page 30, Table 3.1 (final rw, left clumn), malnutritin and weight gain verlked as nutritinal cnditins assciated with alchl cnsumptin. Cancer Cuncil recmmendatins: Insert malnutritin and weight gain under nutritinal cnditins. Draft statement: Page 40, Bx G1.1. This presents the abslute risk ver a lifetime but nly the relative risk (with n indicatin f the magnitude f abslute risk) fr each drinking sessin. It is therefre incnsistent with Bx 2.1 (page 23), which prvides detail n the differences between relative and abslute risk. Cancer Cuncil recmmendatins: Include abslute risk in Bx G1.1. Draft statement: Page 43, sectin 1(b) and the crrespnding sectin in Appendix 5 (page 99). This sectin refers t alchl dse-respnse in terms f the risk f develping alchl-related diseases. The secnd WCRF reprt 1 is particularly relevant in this cntext, as it shws there is n generally safe threshld fr alchl cnsumptin in relatin t cancer risk a significant change in the evidence frm the first reprt, published in 1997, which identified a mdest cnsumptin threshld belw which n cancer risk was bserved. Cancer Cuncil recmmendatin: Insert int page 43, sectin 1(b), paragraph 2: An imprtant recent change in the evidence n dse-respnse in relatin t cancer risk is the Wrld Cancer Research Fund s finding in 2007 that there is n safe cnsumptin threshld. 1 Draft statement: Page 51, Bx G2.1, Initiatin f alchl use at a yung age may increase the likelihd f negative physical health prblems understates the increased risk f cancer linked t prlnged expsure t alchl, a carcingen. Cancer Cuncil recmmendatin: Add sentence, Prlnged expsure t carcingens, including alchl, increases cancer risk. Draft statement: Page 99, under heading Diabetes, paragraph 2. Errneusly states that 30g alchl is 2 standard drinks. Cancer Cuncil recmmendatin: Change t 3 standard drinks. Draft statement: Page 100, heading Appetite. This is ptentially misleading, as the key issue is malnutritin rather than appetite. In additin, there is incnsistent evidence n alchl as an appetite stimulant in cancer patients and n evidence t supprt alchl as 6

7 an appetite stimulant in peple with anrexia. Cancer Cuncil recmmendatin: Change heading t Malnutritin r Undernutritin. Use the sectin under this heading t include the nutritinal prperties f alchl at high and lw use. Draft statement: Page 100, under heading Obesity. This sectin discusses the energy density f alchl, but the nutrient density is nt mentined in either this r the preceding appetite sectin. Cancer Cuncil recmmendatin: Add infrmatin n nutrient density under the renamed previus heading, Malnutritin. Draft statement: Pages , Table A5.1, heading, clumn 1 is 69 years. Cancer Cuncil recmmendatin: Amend heading t Study. Cnclusins The Cancer Cuncil Australia again cmmends the NHMRC n the draft. As evidence n the link between alchl cnsumptin and cancer cntinues t emerge, this is in ur view a timely pprtunity t prvide clear advice t all Australians n the cancer risks related t alchl by adpting The Cancer Cuncil Australia s recmmendatins. References 1 Wrld Cancer Research Fund, Fd, nutritin, physical activity, and the preventin f cancer: a glbal perspective, Internatinal Agency fr Research n Cancer, IARC Grup 1 classificatin fr Alchlic beverages and Ethanl in alchlic beverages 3 Australian Institute f Health and Welfare, Cancer in Australia: an verview,